July 26, 2002

Mr. Jeffery Stollenwerk

Regional Supervisor

Minnesota Pollution Control Agency

525 Lake Avenue South, Suite 400

Duluth, MN  55802

 

RE:           

Minnesota Pollution Control Agency’s Wastewater Treatment Facility Operations Awards Selection Criteria

Dear Mr. Stollenwerk:

The Minnesota Wastewater Operators Association (MWOA) Executive Board met on July 23, 2002 and had discussed your request for input on the selection criteria used in determining the recipients of the Wastewater Treatment Facility Operations Award.  We are pleased that the Agency has recognized the deficiencies in this awards program and that you have considered us for input for corrective actions.

Many of our members feel there has been an unwarranted elimination of facilities for consideration of these awards as the current criteria is more focused on administrative compliance rather than the actual performance of meeting effluent water quality limits.  Since we have very diverse operations, we also believe that the current process uses criteria that is not under the control of certain wastewater operations and thus unfairly eliminates them for consideration of the awards.  It is unfortunate that the system now places more emphasis on the proper documentation of any performance rather than recognizing and promoting the excellent performance that is controlled by the wastewater operators. We believe the latter was the original intent of the Agency’s awards program and we would like to see it restored to the prestige and credibility these awards deserve.

We also do not want to make light of the administrative obligations this profession has and may suggest that a tiered award program be considered by the Agency for different levels of regulatory compliance.  Such a system may lend itself to better address the diverse levels of operations and the variability of regulatory responsibilities represented by our membership.

 In review of your discussions to changes to the current criteria, we believe the Agency is on course toward making progress in developing a more equitable process in recognizing outstanding or excellent performance in our industry.  We would appreciate if you would update us on which items under discussion have or will be incorporated in the final selection criteria.

We are encouraging our membership to respond to your request for input, as we believe there may be some apathy because of past negative experience with your current criteria and selection process.  It may take additional mutual effort and time to restore this awards program to the prestigious level it deserves.

For further information on our organization’s position on this issue and or for additional comments or clarifications, please contact our Secretary/Treasurer Mr. Jim Miller

Sincerely,

Jerry Balbach, President

Minnesota Wastewater Operations Association